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Analysis of Draft of GB 9685 National Standard for the Uses of Additives in Food Contact Materials and Articles in China

original article from CIRS

National Health and Family Planning Commission of the People’s Republic in China (NHFPC) issued GB 9685 Draft of National Standard for the Uses of Additives in Food Contact Materials and Articles on 20 Jan, 2015. From the GB 9685 Draft, key revisions were found in both content and format of the draft version. The Draft has been released to the public for consultation. It has no legal effect for the moment, though, it provides the guidance on the usage of food contact material additives for food contact materials and articles manufacturers. Followings are the detailed highlights of GB 9685 Draft.

First of all, in order to further clarify the additive application scope, the name of GB 9685 has been changed into “the Uses of Additives in Food Contact Materials and Articles”, which is more internationally accepted. The definition of “articles” include food packaging, food container, food tableware; the products such as coating, ink and adhesive which will come into contact with foods directly or indirectly are also included; and the articles like machinery, piping, conveyor belts, containers and utensils which are used in food production, processing, transportation, storage and other food related processes also fall into the category. Detergents, disinfectants or public water facilities are exclusions. Attention should be paid to the word ‘indirectly’, which means that in the future, even though the materials are not actually contacting with the foods directly, as long as there is still possibility that the material will contact with the food, the use of the additives shall also meet the requirements in GB 9685.

In addition, significant changes are made to the content and format of Annex A “Approved Additives and Using Requirements in Food Contact Materials and Articles” in the Draft. According to the application scope of additives, Annex A has been separated into 7 parts from Table A.1 to Table A.7 including plastic, coating, rubber, ink, adhesive, paper and other relevant products. A code system has been established for each substance to improve the function of the search engine.

A health risk assessment will be made based on a series of relevant substances instead of a single substance. In order to improve the risk control and administrative processes, the concept of Specific Migration Limit (SML) in old GB9685-2008 (SML for single substance) has been replaced with a new concept of Total Specific Migration Limit (SML/(T)). In addition, the concept of SML/(T) has also been adopted by metallic elements (Barium, Cobalt, Copper, Ferrum, Lithium, Manganese, Zinc).

The biggest change in the Annex is that although some additives will be forbidden to be used in food contact materials and articles, a significant number of substances are going to be allowed in the draft. Below is a table showing the detailed changes in the GB 9685 draft.

Tremendous changes have been made to GB 9685 draft. The usage requirements of the FCAs are getting stricter, though, the number of substances approved to be used in FCA has been increased. Compared to GB 9685-2008, the new GB 9685 draft is more scientifically reasonable and more internationally accepted, which is getting closer to the FCM regulations in developed countries, such as Japan and USA.

It is recommended that enterprises take actions to check the updated contents of the new draft and comply with the new regulations as early as possible to ensure the successful business in China.

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Draft of GB 9685 Uses of Additives in Food Contact Materials and Articles (CN version free download)

If you are interested in getting the English version of the Draft of GB 9685, please feel free to contact us.

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